Placeholder document. This is a working template prepared by Nexinity for internal review. It must be reviewed and approved by qualified legal counsel before it is published or relied upon by users. Replace the placeholder fields (marked TBD) with confirmed company details.
Last updated: [DATE TBD]
1. Controller
The data controller for personal data collected via this website is Nexinity Sp. z o.o., Warsaw, Poland. You can reach our Data Protection Officer at dpo@nexinity.eu (TBD).
2. What we collect
- Contact-form data: the data you enter into our forms (name, business email, phone, company, country, monthly EUR volume estimate, and your remarks).
- Server logs: IP address, browser user agent, time of access, requested URL — retained 90 days for security and abuse prevention.
- Cookies: strictly-necessary cookies for site functionality plus, with your consent, analytics cookies. See our Cookie Policy.
3. Why we process it
- To respond to your enquiry (legal basis: Art. 6(1)(b) and 6(1)(f) GDPR — taking steps prior to entering into a contract, and legitimate interest).
- To operate and secure the website (Art. 6(1)(f) GDPR — legitimate interest).
- To comply with our regulatory obligations as a Polish payment institution (Art. 6(1)(c) GDPR).
4. How long we keep it
- Contact-form leads: 24 months from last interaction, then deleted or anonymised.
- Server logs: 90 days.
- Records required by financial-services law: as required by Polish AML and KNF rules (typically 5 years).
5. Who we share it with
We share personal data only with processors operating under a GDPR-compliant data-processing agreement — primarily our hosting provider (AWS EU regions), CRM provider (TBD), and email-sending provider (TBD). We do not sell personal data.
6. International transfers
Where personal data is transferred outside the EEA, we rely on Standard Contractual Clauses (Decision 2021/914) and, where applicable, supplementary safeguards.
7. Your rights
You have the right to access, rectify, erase, restrict processing of, port, and object to processing of your personal data, as well as to lodge a complaint with the Polish data protection authority (UODO, uodo.gov.pl) or your local supervisory authority.
8. Contact
privacy@nexinity.eu (TBD) — we will respond within 30 days.